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KIRVEN v. COMMISSIONER

Docket No. 10631-75.

36 T.C.M. 132 (1977)

T.C. Memo. 1977-28

Louis C. Kirven and Blanche W. Kirven v. Commissioner.

United States Tax Court.

Filed February 1, 1977.

Attorney(s) appearing for the Case

Joseph H. Blackwell, 1300 E. 9th, Cleveland, Ohio, for the petitioners. R. Gary Lowen, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Chief Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the years 1972 and 1973 in the amounts of $860.19 and $2,705.14, respectively. All of the adjustments made in the notice of deficiency have been conceded by petitioner; however, in an amended petition, petitioners have attempted to raise a new issue involving a purported loss on worthless stock under section 1244.

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